All on hold for non-dom legislative changes for now…

Due to the snap General Election and the lack of time to fully consider the pre-election Finance Bill (the longest on record at 762 pages), much of the draft legislation was cut from the committee stage debate that took place yesterday afternoon. The draft legislation that has been cut includes the following changes applicable to non-doms and offshore trusts:

Schedule 13:

• The new concept of a returning UK dom (a.k.a. formerly domiciled resident)
• Reducing deemed domicile status from 17 out of 20 years to 15 out of the previous 20 tax years
• Introduction of deemed domicile status for income tax and capital gains tax purposes
• Treatment of offshore trusts settled by non-domiciled settlors who have retained an interest (the protections)
• Rebasing of foreign assets – to allow non-doms who have previously paid the remittance basis charge to rebase their foreign assets for capital gains tax purposes as at 5 April 2017
• Cleansing of offshore accounts –to allow non-doms who have claimed the remittance basis since April 2008 to segregate their offshore funds in the two year period to 5 April 2019

Schedule 14:

• Transfer of assets abroad legislation (which was due to stop taxing non-dom/UK resident settlors on trust income as it arises from 6 April 2017)
• The value of offshore trust benefits for UK resident beneficiaries

Schedule 15:

• Inheritance tax on overseas property representing UK residential property – due to be treated as UK property from 6 April 2017

The clauses now dropped are expected to return in a Bill after the election regardless of who wins, for scrutiny at committee stage.

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